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    <description>Royalty expenditure was treated as prima facie inadmissible where tax at source had not been paid during the relevant previous year, so the claim could be adjusted on processing of the return. Because the mistake was apparent from the return and accompanying documents already on record, the intimation under section 143(1)(a) was capable of rectification under section 154. The later withdrawal of the claim in a revised return did not change the position for processing the original return, and the additional tax adjustment was sustained.</description>
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